Notes from the Scientific Department

Department of Agriculture to Lift Vegetable Protein Restrictions on School Lunch
After years of internal debate, the Food and Nutrition Service of the USDA has proposed an update of its requirements for the use of "vegetable protein products" in the national school lunch program. The Department cites changes in food technology and analysis since the current provisions were put into place as the rationale for the proposed change. Progress in the area of nutrition science is also a factor. According to the Department, "We are looking for ways to enhance flexibility for menu planners and to assist them in meeting the 1995 Dietary Guidelines for Americans." Reduction of total fat and saturated fat in school meals, while maintaining calories and cost-effectiveness, were primary goals.

One of the provisions of greatest interest to vegetarians has been the "30% rule" that restricted the substitution of vegetable protein for meat, poultry, or seafood to not more than 30% of a product. Because of this restriction, foods such as soy hotdogs and veggie burgers have not qualified for inclusion in the national school lunch (and breakfast) program. The USDA is now proposing that this restriction be lifted, opening the way for 100 percent vegetarian and vegan food products to be added to school menus.

The full text of the USDA's proposed rules is available in the July 20, 1999, Federal Register (Volume 64, Number 138, pages 38,839-38,844).

The Vegetarian Resource Group submitted written comments supporting the USDA's proposed rules. The full text of VRG's comments follows.

Mr. Robert M. Eadie
Food and Nutrition Service
United States Department of Agriculture
3101 Park Center Drive
Alexandria, Virginia 22302

Comments of The Vegetarian Resource Group on the US Department of Agriculture's request for comments as published in the July 20, 1999, Federal Register, Vol. 64, No. 138, pages 38,839-38,844: Modification of the "Vegetable Protein Products" Requirements for the National School Lunch Program, School Breakfast Program, Summer Food Service Program and Child and Adult Care Food Program.

Dear Mr. Eadie:

The nonprofit Vegetarian Resource Group (VRG) represents over 25,000 consumers and health professionals with an interest in the interrelated issues of health, nutrition, ecology, ethics, and world hunger. VRG appreciates having the opportunity to submit comments in response to the US Department of Agriculture's proposed rule on the use of alternate protein products in school meals and children's feeding programs. VRG supports the Department's commitment to continuous improvement of the current regulations. We favor the implementation of policies that will aid in improving the overall nutritional quality of meals while at the same time increasing the flexibility of programs in meeting current nutritional recommendations. The proposed modification to the existing rule is an example of such an improvement.

Changing the Name From VPP to APP: VRG is not opposed to changing the name from vegetable protein products (VPP) to alternate protein products (APP). However, if the requirement that APP only be of plant origin is removed, then schools and institutions should be required to make ingredient lists available to recipients at the point of purchase for meals made with APPs. Those wishing to avoid animal products will want to be made aware of the presence of animal products in foods offered.

Removing the 30 Percent Limit on Meat, Seafood, and Poultry Substitutions: VRG is strongly in favor of removal of this requirement and supports the Department in this modification of the rule. The rationale for this requirement is no longer supported by science, and the requirement stands in the way of creative menu alternatives that are very much in demand by certain segments of the school and institutional meals market. Removal of this long-standing requirement will also open up additional menu options that will further assist programs in meeting current dietary recommendations.

Removal of the Fortification Requirement: VRG supports the Department's proposal to remove the fortification requirement for APPs on the basis of scientific evidence rendering its use unnecessary and possibly detrimental to meal recipients. Removal of this requirement will also increase the selection of products available to programs and further assist them in meeting their nutritional goals.

Update of the Protein Quality Test
VRG supports the Department's proposal to use Protein Digestibility Corrected Amino Acid Scores (PDCAAS) in place of the Protein Efficiency Ratio (PER) test currently in use. This change would be in keeping with prevailing scientific opinion and would confer consistency with FDA regulations for same.

The Vegetarian Resource Group applauds the Department's commitment to continuous improvement of the regulations governing the implementation of school and institutional meal programs. VRG looks forward to continued efforts to increase the number of options for our culturally diverse program participants as well as innovations that will aid in achievement of nutrition goals.

Respectfully submitted,

Suzanne Havala, MS, RD, LDN, FADA
Scientific and Policy Advisor
The Vegetarian Resource Group

VRG in the News
VRG Nutrition Advisor Reed Mangels was interviewed by the Denver Post for a story about teen vegetarians, as well as by the Wall Street Journal and Prevention magazine for stories about vegetarian kids.

VRG Nutrition Advisor Suzanne Havala was interviewed by Natural Health magazine for an article about vegetarian diets and by Vegetarian Times magazine for stories about milk and snack foods. She was also interviewed by eHealth and Food & Wine magazines for stories about vegetarian nutrition.

VRG Foodservice Activities
VRG Foodservice Advisor Nancy Berkoff, RD, EdD, continues to be busy on the veggie-foodservice scene. Recently, she made a presentation to the Los Angeles, CA, Unified School District for a "train the trainer" program for foodservice directors on how to cook vegan food for kids. If accepted, the training results could reach 90,000 kids, staff, and faculty.